Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
ITAT held that the reassessment proceedings initiated under s.147 and notice issued under s.148 are invalid because the Pr. CIT's approval under s.151(2) was a mechanical, non-application of mind endorsement. Relying on controlling High Court precedent that condemns perfunctory sanctions evidenced by mere recorded satisfaction, the Tribunal found the sanction to reopen was vitiated. Consequentially, the s.148 notice was held bad in law and the consequent reassessment order was quashed. The appeal by the assessee was allowed and the reassessment proceedings set aside.
ITAT held that the reassessment proceedings initiated under s.147 and notice issued under s.148 are invalid because the Pr. CIT's approval under s.151(2) was a mechanical, non-application of mind endorsement. Relying on controlling High Court precedent that condemns perfunctory sanctions evidenced by mere recorded satisfaction, the Tribunal found the sanction to reopen was vitiated. Consequentially, the s.148 notice was held bad in law and the consequent reassessment order was quashed. The appeal by the assessee was allowed and the reassessment proceedings set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
